Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax liability as follows:
Year Deficiency 1976 ......................... $18,249.00 1977 ......................... 16,241.00 1979 ......................... 46,003.00 1980 ......................... 54,174.00 1981 ........................
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